Die kartellrechtlichen Sanktionssysteme der USA und der EU vor dem Hintergrund ihrer jeweiligen Sanktionsumfelder

Both the US and the EU have a variety of measures in place in order to sanction cartels. Some of these measures are generally similar in nature, while others differ materially. The overall architecture of the fight against cartels is affected not only by the specific measures that each jurisdiction applies, but also by the integration of these measures within the broader sanctioning system.
The title illustrates how both sanction systems work and takes particular account of the jurisdictions’ decisional practice and the interrelations within each system. The comparative approach demonstrates that even seemingly similar measures may have entirely different effects within each system.